PRIVACY NOTICE


(“Compass Group”/ “We” /“Us”/ “Our”) is providing this Privacy Notice to inform you of our procedures regarding the collection and use of your Personal Information (“PI”) or Sensitive Personal Data or Information (“SPDI”) that CGI may collect and receive from you. PI and/ or SDPI shall individually be referred to as such and collectively referred to as “Information”.

(“Compass Group”/ “We” /“Us”/ “Our”) ,wherever referred shall mean the entity of “Compass Group” with which you or your designated personnel shall be dealing with or providing PI or SPDI (as the case may be or as the context may require), to in terms of this Notice.

PI or SDPI may relate to said information provided of you or your employees’ or any of your directors, shareholders, representatives or any other or third party, each being referred as “Data Subject”.

“You” or “Your” shall mean you the entity to which this Notice is served in respect of the purpose contemplated herein and by sharing the Information of Data Subject for securing Our services in terms of the purpose contemplated herein, you shall be deemed to have obtained the consent of Data Subject.

This Notice applies only to PI or SPDI that you would provide of Data Subject to CGI for providing Our services in terms of our contractual arrangement for effective rendition of Our services in respect of the purpose contemplated herein.

The information that You provide to Us may include below mentioned details or documents as shall be sought by our designated personnel for the purpose mentioned herein, in order to provide Our services:

  1. User account data (e.g., username, e-mail address);


  2. Purchase data (e.g., object of purchase, purchase amount);


  3. Transaction data (e.g., transaction ID, date of transaction, card issuer, last four digits


  4. of PAN, terminal ID);


  5. Loyalty program data (e.g., member ID, bonus points collected);


  6. Device and meta data (e.g., IP address, device model, OS version);


  7. Location data (only if explicit user opt-in given);


  8. Push notification (in app) tokens (only if explicit user opt-in given); and


  9. If you send us a message: the content of your individual request.


  10. PAN/ Adhaar Card


  11. Other PI or SDPI that helps identification of the Data Subject as may be deemed essential for the requirement of the Purpose

    Separate from the above data, the following data is processed when you visit the S.Market:



The S.Market is equipped with two different kinds of cameras: cameras on the shelves, which

are used solely for inventory management and are technically configured so that customers are not recorded; and cameras built into the ceiling of the S.Market (ceiling cameras). These ceiling cameras record customers’ journey through the store. The camera recordings are

immediately obfuscated after they are generated in such a way that they can no longer be used

to identify you. Only obfuscated camera recordings are temporarily (<100ms) stored for analysis purposes, as described in the following section (“For what purpose and on what legal basis is the processing carried out?”), and then irreversibly deleted. At no point is the analysis data combined with other data about you; it is completely

anonymous and aggregated statistics that cannot be traced back to you or other S.Market customers.

You are not obliged to provide us with any of this data. However, without this data, we will not

be able to provide you with the S.Market and S.Market app and all their functions.


“Purpose” for collection of the Information shall be either of these specified purposes, whether individually or in combination of any of these, which has been communicated to You over email by CGI while sharing this Privacy Notice with You and the said purpose communicated to You over email

shall form part of this Notice as if adopted and incorporated in this Notice to be read along with the Notice and to which this Notice shall pertain:

  1. Rendition of Food Services/Retail Purchase for which registration is required; or


  2. Payment Facilitation for Our service offerings; or


  3. Other as communicated to You.


We will share the aforementioned information internally within SAP /Compass Group Subsidy, including to any of its subsidiaries or affiliates and if required to do so with Government Bodies including statutory, regulatory authorities, law-enforcement agencies and Compass Group auditors.

Compass Group may retain PI or SPDI for as long as there is a business requirement for the retention of the same or if otherwise required under any law.

The Information collected for the Purpose shall accordingly be processed by Compass Group for the fulfillment of the Purpose. Note that Compass Group adopts reasonable security practices and procedures to protect PI or SPDI and complies with requisite applicable data privacy laws governing the processing of the Information.

You hereby acknowledge and understand that Information may be processed in the aforementioned manner and by availing or securing our services for the Purpose contemplated herein, You shall be deemed to have understood the contents herein and shall further be deemed to have provided Your and Data Subject consent to Us in terms of this Notice

Compass Group 08.2025